Payment for Order Flow (PFOF) and Gamification: Your Questions Answered
Summer Enforcement Action Review; Raising Money in a Pandemic - Investment Management Roundtable Discussion
Investment Management and Private Funds Roundtable – June 2020
Videocast: Asset management regulation in 2020 videocast series – FinTech initiatives
Videocast: Asset management regulation in 2020 videocast series – Fiduciary investment advice: The patchwork emerges
Videocast: Asset management regulation in 2020 videocast series – SEC enforcement
Videocast: Asset management regulation in 2020 videocast series – Complying with new SEC rules for broker-dealers
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Regulation Best Interest Videocast Series: Establishing An Investment Platform Post-Regulation BI
Investment Management Update - Focus on Data Privacy and Cybersecurity
Securities and Exchange Commission. Customer ID requirements. On May 13, 2024, SEC and FinCEN proposed a rule designed to make it more difficult for criminal actors to establish customer relationships with investment...more
Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more
Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more
It is a dramatic understatement to describe 2023 as a busy year in the United States for asset management regulation. With 24 rules adopted and 18 new rules or rule amendments proposed, the US Securities and Exchange...more
Suitability in the sale of annuity products has been a topic of state regulation since at least 2003 - well before the federal focus on “Best Interest.” State insurance regulators have overseen the sale of annuities to ensure...more
Promoting securities, cryptocurrency, and other investment opportunities is fraught with legal risks. Individuals who engage in promotional activities must ensure that they have a clear understanding of the federal laws and...more
A staggering decline in value is not the only recent source of significant concern for cryptocurrency companies. In remarks made at the annual meeting of the Financial Industry Regulatory Authority (FINRA) earlier this month,...more
The Financial Industry Regulatory Authority issued a regulatory notice clarifying the scope of supervisory liability under FINRA Rule 3110 of a broker-dealer’s chief compliance officer (CCO) (Regulatory Notice). FINRA’s Head...more
Continued FINRA Focus - If regulatory developments in 2020 are any indication, FINRA’s efforts to protect senior customers from financial exploitation and vulnerability will continue in 2021 and beyond....more
Firms permitting the creation and operation of custodial accounts related to Uniform Transfers to Minors Act (UTMA) or Uniform Gifts to Minors Act (UGMA) transactions must take special notice of Financial Industry Regulatory...more
It was a year filled with tantalizing tidbits and many loose ends. 2019 marked the 10th year since blockchain technology was released into the wild by its still unknown inventor, Satoshi Nakamoto, who mined the first bitcoin...more
The Securities and Exchange Commission released the report from the August 2019 Government-Business Forum on Small Business Capital Formation. The Annual Forum provides an opportunity for market participants to meet and...more
On July 8, 2019, the staff of the U.S. Securities and Exchange Commission (“SEC”) Division of Trading and Markets and the staff of the Financial Industry Regulatory Authority (“FINRA”) issued a joint statement outlining...more
Last week, the Staffs of the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) (collectively, the Staffs) released a Joint Statement concerning the application of the SEC’s...more
On June 5, 2019, the Securities and Exchange Commission (“SEC”) voted to adopt “Regulation Best Interest,” which is intended to increase the duties a broker-dealer owes to its clients. While SEC-registered investment advisors...more
In connection with the US Securities and Exchange Commission’s (SEC) proposed Regulation Best Interest, the Financial Industry Regulatory Authority (FINRA) has asserted (with some case law support from the SEC) that its...more
The New York Stock Exchange LLC (“NYSE”) proposes to amend Rule 2 to remove the FINRA or other national securities exchange membership requirement for member organizations. ...more
On April 18, the SEC voted to propose major rule changes to reconcile and clarify the standards of conduct that apply to broker-dealers and investment advisers. ...more
FINRA recently proposed to remove the broker’s “control” of a securities account as a required element of a “quantitative suitability” violation under Rule 2111....more
In late 2017, FINRA pronounced in Regulatory Notice 17-30 that, "Beginning on October 1, 2018, unregistered persons cannot accept an order from a customer under any circumstances. ...more
FINRA recently published its 2018 Annual Regulatory and Examination Priorities Letter, which identifies opportunities for firms to improve their compliance, supervisory and risk management policies or programs. ...more
On November 24, while everyone was recuperating from their Thanksgiving feast, the NAIC's Annuity Suitability Working Group circulated the Working Group Chair's draft of proposed revisions to the Suitability in Annuity...more
For two years FINRA has made sales and marketing of L-Share variable annuities (VAs) a regulatory and examination priority. Not surprisingly, FINRA in November announced settled actions against eight broker-dealers, alleging...more
Speaking at the Brookings Institution this April, FINRA head Richard Ketchum emphasized the importance of a broker-dealer having a "culture" that favors the firm’s customers when their interests conflict with those of the...more